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Quote from new 2257 reg:
(b) Picture identification card means a document issued by the United States, a State government or a political subdivision thereof, or a United States territory, that bears the photograph and the name of the individual identified, and provides sufficient specific information that it can be accessed from the issuing authority, such as a passport, Permanent Resident Card (commonly known as a ``Green Card''), or other employment authorization document issued by the United States, a driver's license issued by a State or the District of Columbia, or another form of identification issued by a State or the District of Columbia; or, a foreign government-issued equivalent of any of the documents listed above when both the person who is the subject of the picture identification card and the producer maintaining the required records are located outside the United States.
Italicized text indicates that foreign passports are good when both actress and producer are outside of the USA. If you are required to keep the documents at your place of business in the USA, foreign passports would not be acceptable as I read it......but, I'm not a lawyer.
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